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Taxable Dividends
Dividends are taxable income. Sec. 61(a)(7). Respondent
determined that petitioners failed to report $281 in dividend
income received during 1999. Petitioners conceded receipt of
$281 in dividends but maintain that this amount is not taxable
income to them because the dividends were received with respect
to stocks that belonged to Melinda Doxtator and were paid over to
her. For the reasons discussed in connection with our
consideration of petitioners' capital gains in 1999, we conclude
that petitioners have failed to show that any of the stocks
titled in Mrs. Doxtator's name were being held on behalf of
Melinda Doxtator or that any proceeds related to those stocks
were paid over to Melinda Doxtator. Accordingly, we sustain
respondent's determination.
Oneida Tribe Payments
Respondent determined that petitioners failed to report
$3,000 in taxable per capita payments in 1999. Petitioners
contend that the payments are exempt from tax.
The payments at issue were received by petitioners from the
Oneida Tribe and constituted a distribution of the profits from a
casino operated by the Tribe. The payments were reported on
Forms 1099 by the Tribe as taxable nonemployee compensation.
Petitioners first argue that the payments are not per capita
payments because they were not distributed equally to members of
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